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Sayson v. People

The petitioner was charged with estafa through falsification of commercial documents. On the day the defense was to present evidence, the petitioner's counsel was absent and sent a telegram requesting a postponement due to illness. The court denied the request for postponement and rendered a guilty verdict without hearing the petitioner's evidence. The petitioner argued this deprived him of his right to due process. The Supreme Court held that there was no denial of due process as the petitioner waived his right by not properly filing the motion to postpone. The court is also not required to appoint counsel for the petitioner at this stage of the trial. The decision of the Court of Appeals affirming the guilty verdict was also affirmed.

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271 views1 page

Sayson v. People

The petitioner was charged with estafa through falsification of commercial documents. On the day the defense was to present evidence, the petitioner's counsel was absent and sent a telegram requesting a postponement due to illness. The court denied the request for postponement and rendered a guilty verdict without hearing the petitioner's evidence. The petitioner argued this deprived him of his right to due process. The Supreme Court held that there was no denial of due process as the petitioner waived his right by not properly filing the motion to postpone. The court is also not required to appoint counsel for the petitioner at this stage of the trial. The decision of the Court of Appeals affirming the guilty verdict was also affirmed.

Uploaded by

Gloria Chan
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Sayson v. People G.R. No. L-51745 October 28, 1988 Facts: The petitioner, Ramon F.

Sayson, was charged with the crime of Estafa through Falsification of a Commercial Document before the CFI of Manila. The petitioner pleaded not guilty upon arraignment and after several postponements, the prosecution rested its case. On the day of presentation of evidence by defense, the petitioners counsel was absent and later sent a telegram requesting for the cancellation of the hearing due to him being sick. The court denied request for postponement and considered case submitted for decision without evidence from petitioner. Petitioner was rendered guilty by the court which was later affirmed by the Court of Appeals, but imposed lower penalty. Petitioner seeks the reversal of the decision finding him guilty of attempted estafa; he alleges that such decision was rendered depriving him of his right to due process and it was the duty of the court to appoint a counsel de oficio in his behalf in the absence of his own counsel. Issue: Was the petitioner deprived of his right to present evidence? Held: No. The court did not deprive the petitioner of his right to present evidence in denying the motion for postponement of the hearing. The court held that there was no denial of due process since no right can be successfully invoked where it was validly waived. In this case, the petitioner alleged that his counsel had another case at a different court as the reason for his absence before the court received the telegram alleging that the such counsel was sick. Also, the petitioners motion was not filed properly since the 3-day notice required in accordance with procedure was not followed and there was no medical certificate nor affidavit to support the alleged illness of counsel. The petitioners plea that the court should have appointed a counsel de oficio in his behalf is without legal basis. The appointment of counsel de officio is only mandatory at the time of arraignment in accordance with Rule 116, Sec. 6 of the Revised Rules of Court. It is no longer applicable during the hearing of the trial such as the situation of the petitioner. The appeal is denied and the decision of the Court of Appeals is affirmed.

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